least, as much calculated as any other to raise the question of the seal of confession. Again, let us remember that in some districts, such as Durham and Chester, bishops exercised temporal jurisdiction. Even in the King's Courts, as Lord Coke points out, often the judges were priests, before Innocent IV prohibited priests from acting as judges. Pollock and Maitland's History of the Laws of England gives us as a specimen date, that of 16 July 1195, on which there sat in the Court of King's Bench an archbishop, three bishops, and three archdeacons. The same book tells us that: It is highly improbable that at a period when systematization of the common law was proceeding at the hands of "popish clergymen" a rule compelling the disclosure of confession would have grown up. Finally, it is worthy of some observation that there is not a single reported case, textbook or commentary, during the whole pre-Reformation period which contains any suggestion that the laws of evidence did not respect the seal of confession. These grounds seem sufficient to lead to the conclusion that before the Reformation the seal was regarded as sacred by the common law of England. Sir Robert Phillimore in his work on (Anglican) ecclesiastical law makes a definite statement to this effect. The only recorded statute of the English Parliament which deals with the right of confession is the Privilege of Sanctuary Act 1315 (9 Edw. II, c.10). The statute is called Articuli Cleri, and the part referred to deals with the rights of offenders who abjure the realm and, fleeing to a church for refuge, claim privilege of sanctuary. After stating that such persons are to be allowed to have the necessaries of life and that they are to be at liberty to go out of the church to relieve nature, the statute continues as follows: "Placet etiam Domino Regi, ut latrones vel appellatores quandocunque voluerint possint sacerdotibus sua facinora confiteri: sed caveant confessores ne erronice hujusmodi appellatores informent". This law, long obsolete, was repealed in 1863, and is translated in the collections of the Statutes (Statutes of the Realm, I, 173), and in Pickering's edition of "Statutes at Large" (Cambridge, 1782): "And the King's Pleasure is, that Thieves or Appellors (whensoever they will) may confess their Offences unto Priests: but let the Confessors beware that they do not erroneously inform such Appellors". Coke on privilege Sir